Onscreen Dynamics LLC v. EAN Holdings LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Onscreen Dynamics, LLC (Delaware)
  • Defendant: EAN Holdings, LLC (Delaware)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:24-cv-00251, E.D. Tex., 04/16/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Eastern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that touchscreen infotainment systems in Defendant’s rental vehicles infringe two patents related to "virtual bezel" user interface technology.
• Technical Context: The technology addresses the problem of maximizing screen real estate on electronic devices by eliminating physical bezels, while simultaneously preventing accidental inputs from a user's hand gripping the edge of the device.
• Key Procedural History: The complaint notes that the asserted patents, which share a specification, have been cited as references in subsequent patent applications by other technology companies and the USPTO. The ’663 Patent is a continuation of the application that led to the ’917 Patent.

Case Timeline

Date	Event
2013-03-24	Priority Date for ’917 and ’663 Patents
2016-07-19	U.S. Patent No. 9,395,917 Issued
2017-05-09	U.S. Patent No. 9,645,663 Issued
2024-04-16	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,395,917 - Electronic Display with a Virtual Bezel

• Patent Identification: U.S. Patent No. 9,395,917, "Electronic Display with a Virtual Bezel," issued July 19, 2016.

The Invention Explained

• Problem Addressed: The patent’s background section describes the limitations of physical bezels on electronic devices, which serve to prevent unintended screen touches but also reduce the maximum possible display area (Compl. ¶13; ’917 Patent, col. 1:21-41). Removing the physical bezel creates a challenge: how to provide an edge-to-edge display without registering accidental inputs from the user's grip (Compl. ¶13; ’917 Patent, col. 1:32-35).
• The Patented Solution: The invention proposes a touchscreen with two distinct regions: a main "active touchscreen region" with conventional touch response and a "virtual bezel area" along the edges (’917 Patent, col. 4:10-24). This virtual bezel is part of the display and shows content, but gestural software gives it a different, limited mode of response to touch, thereby preventing unintended interactions while allowing the user to hold the device normally (’917 Patent, Abstract; col. 2:6-15).
• Technical Importance: This design principle facilitates the creation of "bezel-less" or "edge-to-edge" screens, a significant aesthetic and functional trend in consumer electronics, by managing the usability trade-offs (Compl. ¶14; ’917 Patent, col. 1:41-49).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2, 4, 7, and 9 (Compl. ¶52).
• The essential elements of independent claim 1 include:
  • A "virtual bezel area" with a touchscreen layer having a "first mode of response" and displaying a "first portion of content."
  • An "active touchscreen region" disposed within the virtual bezel area, having a "second mode of response" and displaying a "second portion of content."
  • A "gestural software application" that produces the "first mode of response" in the virtual bezel area, which is configured to "selectively interpret touch-based inputs as intentional user input" meant to affect the content in the active region.
• The complaint reserves the right to assert additional claims (Compl. ¶52).

U.S. Patent No. 9,645,663 - Electronic Display with a Virtual Bezel

• Patent Identification: U.S. Patent No. 9,645,663, "Electronic Display with a Virtual Bezel," issued May 9, 2017.

The Invention Explained

• Problem Addressed: As a continuation of the ’917 Patent, the ’663 Patent addresses the same technical problem of creating a larger, bezel-free display area while avoiding inadvertent screen touches (Compl. ¶33; ’663 Patent, col. 1:27-41).
• The Patented Solution: The patented solution is a "display system" that similarly uses software to create two functionally distinct areas on a single physical touchscreen: an "active touchscreen region" with one mode of response and an adjacent "virtual bezel region" with a second, different mode of response (Compl. ¶35; ’663 Patent, Abstract). The virtual bezel region is configured to "selectively interpret" inputs, distinguishing intentional commands from accidental contact (’663 Patent, cl. 1).
• Technical Importance: The invention contributes to the design of devices with maximized screen-to-body ratios by providing a software-based method to replicate the ergonomic function of a physical bezel (Compl. ¶33; ’663 Patent, col. 1:46-59).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2, 3, 6, 9, and 11 (Compl. ¶55).
• The essential elements of independent claim 1 include:
  • A "touch-sensitive display screen."
  • An "active touchscreen region" with a "first mode of response" to a "first set of touch-based inputs."
  • A "virtual bezel region" adjacent to the active region, with a "second mode of response" to a "second set of touch-based inputs."
  • "Non-transitory memory storing a gestural software application" configured to produce the "second mode of response" in the virtual bezel region, which "selectively interpret[s] touch-based inputs as intentional user input."
• The complaint reserves the right to assert additional claims (Compl. ¶55).

III. The Accused Instrumentality

Product Identification

The complaint accuses "unlicensed vehicles that include electronic devices with touchscreens providing claimed features" (Compl. ¶52, ¶55). Defendant EAN Holdings, LLC is the parent of rental car companies, and the accused instrumentalities are the infotainment systems within their vehicle fleet.

Functionality and Market Context

The complaint alleges that the touchscreen systems in Defendant's vehicles incorporate the patented virtual bezel technology (Compl. ¶52, ¶55). It references, but does not include, preliminary claim charts (Exhibits C-H) that purportedly detail the infringing capabilities (Compl. ¶52, ¶55). The complaint does not otherwise provide specific technical details on the operation of the accused systems.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim chart exhibits that were not provided with the filing (Compl. ¶52, ¶55). The infringement theory, based on the complaint’s narrative, is that the accused vehicle infotainment systems possess touchscreens that operate with two distinct regions. An inner "active" region is alleged to have a standard touch response, while an outer "virtual bezel" region, which also displays content, is alleged to have a different, limited touch response governed by software. This software allegedly distinguishes between accidental contact and intentional gestures within the bezel region, thereby infringing the asserted claims.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The patents’ specifications frequently use handheld mobile devices as exemplary embodiments (’917 Patent, col. 4:7-10). A potential point of dispute may be whether the patent claims, which use the broader term "electronic device," should be interpreted in light of these specific examples or if they unambiguously cover embedded automotive infotainment systems.
• Technical Questions: The complaint asserts that the accused systems practice the claimed "virtual bezel" functionality, but provides no specific evidence of how they operate. A central question for the court will be a factual one: does the software in the accused systems perform the specific function of "selectively interpret[ing] touch-based inputs as intentional user input" in an edge region, as required by the claims? Or does it employ a more generic form of edge touch rejection that does not map onto the claim limitations?

V. Key Claim Terms for Construction

Term 1: "virtual bezel area"

• Context and Importance: This term is central to the invention's identity. The outcome of the case may depend on whether the edge regions of the accused touchscreens meet the definition of a "virtual bezel area." Practitioners may focus on this term because its scope will determine the applicability of the patent to a wide range of modern edge-to-edge displays.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines it as a "secondary touchscreen display area" used to "prevent any unintended touch" and which "serves as continuation of the display, extending the visual content" (’917 Patent, col. 2:10-18). This language could support an interpretation that covers any screen edge that displays content but has some form of touch-rejection.
  • Evidence for a Narrower Interpretation: The specification also states the area may have "limited interactivity" and process inputs "requiring a conscious and non-accidental effort" (’917 Patent, col. 2:19-22). Specific embodiments show a defined frame around the active area (’917 Patent, Fig. 2-3). This may support a narrower construction where the area must not only reject accidental touches but also be configured to accept a distinct set of intentional, non-accidental inputs.

Term 2: "selectively interpret touch-based inputs as intentional user input"

• Context and Importance: This phrase from claim 1 of both patents defines the specific function of the software in the virtual bezel. Infringement will hinge on whether the accused software performs this precise interpretive action.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "selectively" could be argued to simply mean distinguishing between any two classes of input (e.g., accidental vs. intentional), a basic function of many touch-rejection systems. The patent describes the virtual bezel as having "limited responsiveness" (’917 Patent, col. 3:58-59).
  • Evidence for a Narrower Interpretation: The specification provides specific examples of what constitutes an "intentional" input in the virtual bezel, such as swipes for navigation or a long tap for a "home" function (’917 Patent, col. 7:28-32, Fig. 10). This could support a narrower reading that requires the software to do more than just ignore touches; it must be programmed to recognize and act upon a specific, alternative set of gestures within the bezel region.

VI. Other Allegations

The complaint does not contain specific counts or factual allegations for indirect infringement or willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

1. A core issue will be one of definitional scope: can the term "virtual bezel area", which is described in the patents with reference to handheld devices, be construed to cover the user interface architecture of the accused embedded automotive infotainment systems?

2. A key evidentiary question will be one of functional correspondence: does the software in the accused vehicle systems perform the specific, claimed function of "selectively interpret[ing] touch-based inputs as intentional user input" within an edge or bezel region, or does it merely employ a generic touch-rejection algorithm that is technically distinct from the patented method? The resolution will likely depend on technical evidence revealed during discovery.